QQ: Existing Frame, No Fire Label

QQ: Existing Frame, No Fire Label

Regarding an existing fire door assembly – the door has a fire label but the frame does not. Is the frame required to have a label?

Ideally, a fire door frame will have a label that is visible and legible. This label includes valuable information that will help a fire door inspector and/or AHJ confirm the code-compliance of the frame. NFPA 80 states:

4.2.1.4 The label for fire door frames shall contain the following information:(1) The words “fire door frame”(2) The manufacturer’s company name or a code that can be traced back to the manufacturer(3) The marking of a third-party certification agency(4) The fire protection rating of the frame(5) The fire test standard designation to which it was tested

NFPA 80 goes on to clarify a few things:

The label does not have to include the length of the fire protection rating for frames rated up to 3 hours with masonry anchors installed in masonry walls, or for frames rated up to 90 minutes with wood stud or steel stud anchors installed in gypsum board walls.

If no hose stream tested was conducted, a statement shall be provided.

A frame can be marked with an embossment instead of a label – the embossment must include the certification agency and the manufacturer’s name or a code that indicates the manufacturer.

NFPA 80 clearly requires a label or embossment for fire door frames, BUT – NFPA 101 does offer a little leeway on this. In the 2015 edition, this paragraph was added:

8.3.3.3.4 In existing installations, steel door frames without a label shall be permitted where approved by the authority having jurisdiction.

Prior to the 2015 edition, this was referenced in Annex A – Explanatory Material:

8.3.3.2.3* Labels on fire door assemblies shall be maintained in a legible condition.

A.8.3.3.2.3 In existing installations, it is important to be able to determine the fire protection rating of the fire door. However, steel door frames that are well set in the wall might be judged as acceptable even if the frame label is not legible.

For an existing frame without a label installed in a location where a fire door assembly is required, the options are:

The AHJ could allow the non-labeled frames to remain as-is – the least expensive option but could create problems with future inspections.

The frames could be re-certified/re-labeled in the field – this is not an inexpensive undertaking but would clearly communicate that the frames are compliant with the listing requirements.

The non-labeled frames could be replaced – obviously not ideal cost-wise, and the new frame may not be anchored as well as the existing frame.

Does anyone have experience with how CMS and The Joint Commission address existing fire door frames without labels? Please share your insight in the comments!

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2 Comments

In my experience both CMS AND TJC would rate the opening as non-compliant, assuming the door is rated and the opening continues to require protection. For an “abandoned in place” fire rated assembly where a fire rating is no longer being maintained both CMS and TJC actually require the labels to be removed so it is not uncommon to find what looks like fire rated assemblies without labels in many HCO’s. Removing labels not so hard; removing embossing from frames a tad bit more difficult.